OG status:

Fully open

Author unit / section:

Construction sector

Target audience:

Construction division staff and construction inspectors

Summary

This SIM replaces SIM02/2008/02 and provides guidance to CD staff on recording work on COIN undertaken in accordance with the division’s Plan of work 2009/ 10. It should be read in conjunction with the work recording OM 2009/07, the divisions work plan and its operational supporting guidance.

Introduction

There are a number proactive operational work streams detailed within the divisions Plan of work 2009/10. The information gathered during the delivery of these is vital to the division’s ability to assess standards and evaluate the effectiveness of its plan as a whole. This SIM provides guidance on how the information generated should be recorded on COIN and the circumstances when Cases and IRF service orders should be used. This information is summarised in Appendix 1 – work recording aide memoir.

Timing

The changes to categories described in this SIM will take effect from 13 April 2009. This date is to enable staff to use the current categories to record their 2008/09 work until 12 April 2009.

Recording inspection work

The IRF Construction Service Order (IRF C) should be used to record ALL inspection work. This includes visits to head offices, dealings with CDM duty holders and other intervention visits. The only exceptions are asbestos license assessments and matters of evident and potential major concern.

Inspection cases can still be used where appropriate as a master case to link various visits to one another (e.g. as part of a National Lead Inspector intervention - NLI). However, the details, time etc should be recorded on the IRF C. This is to simplify the recording process and avoid the need to create additional timelines. Further guidance on recording NLI/ LLI/ HO PI interventions will be provided in due course where appropriate.

The IRF C should be completed in line with existing COIN guidance.  Further help is available in a specific ‘How to’ guide in relation to the IRF C at this site.

Selecting the appropriate IRF C work stream

Because work is being recorded on the IRF C against work streams instead of topics there is no need to record on more than one line at a time. For this reason all of the work streams have been defaulted to ‘not discussed’. This is in order to minimise the need to close unused lines. The relevant work stream therefore needs to be actively selected by changing the ‘not discussed’ field to ‘present’. This is a change to last year’s instructions.

Due regard should be taken of the descriptors below when deciding the appropriate work stream to record against on the IRF C. Where no specific category is applicable then ‘CD Construction Other’ should be used instead.

Work stream	Recording criteria
CD Refurb/ Repair/ Maint	All work associated with refurbishment, repair or maintenance to ANY existing building including: Refurbishment work linked to specific NLI clients Structural and re-roofing work Extensive internal / external renovation Soft strip Minor, domestic single storey etc extension Maintenance/ repair work – e.g. gutter replacement, roof repairs, mortar pointing, work by tradesmen Demolition/ site preparation where part of an overall refurbishment project
CD Homebuild	All work associated with NEW residential buildings including: Houses, flats, apartments, high-rise buildings Homebuilders and Developers Houses, flats, apartments Homebuild specific major projects or NLI/ LLI interventions Demolition/ site preparation where part of an overall homebuild project
CD Major projects & interventions	Work linked to major projects or NLI/LLI interventions. Only record where there is an agreed written intervention plan in place for the project, or where the work is associated with a planned NLI/LLI initiative  EXCEPT where Refurb/ Repair/ Maint or Homebuild specific
CD Asbestos licensing	Inspections of notifiable work by asbestos licence duty holders and waiver requests where the information is of particular note
CD Crane suppliers & hirers	All work by nominated inspectors associated with head office visits to tower crane suppliers. Site based crane work to be recorded against the overarching industry sector (homebuild etc)
CD Construction  other	All work not otherwise captured by another work stream above including: Discussion of CDM duties where not captured elsewhere Construction of new/ significant extensions to non-residential buildings such as factories, hospitals, schools, shops, leisure facilities, offices, care homes Civil engineering and utility work Demolition and site preparation where not included above

Risk control indicator

For the 09/10 work year ALL IRF C work streams are required to have their relevant RCI rated. This is a change to the previous arrangements in SIM 02/2008/02. The RCI guide is attached at Appendix 2 - IRF work stream rating and details the assessment scale to be used as well as the priority topics for each work stream. Further details on each topic are contained within the Division’s Plan of Work.

Inspection ratings scores

Inspection Ratings Scores only need to be completed where an inspector has enough information to make an informed judgment about a duty holders overall health and safety performance (i.e. not just site based). This would include circumstances such as:

• Head office visits to discuss poor site standards
• Other head office visits when the inspector considers enough information has been obtained; e.g. when clearing a notice or carrying out a post prosecution visit
• As part of a National or Local Lead Inspector Scheme
• Dealings with the self employed/ small companies where a site visit is sufficient to inform/ indicate overall performance

The assessment scale to be used is attached at Appendix 3. Scores should be reviewed and changed as necessary at follow up visits to poor performers. There is no need to complete any inspection ratings scores following visits in other circumstances.

Notes summary and detail fields

The notes summary and detail fields should contain the mandatory information outlined in the work recording OM. Whenever an RCI is given a score of 5 or 6 the action taken and the reasons for taking that action must also be recorded.

In addition to this the Division is very keen to obtain information from COIN on the outcomes/ results of the work undertaken, particularly in relation to innovative solutions or challenges to achieving the standards set out in the project plans. Where it is considered useful to draw these matters to the attention of the sector it would be beneficial if Inspectors cold precede any relevant information in the detail field with the words ‘outcome’.

Matters of evident concern and potential major concern

Visiting staff should be aware that there are specific instructions for all FOD staff relating to situations where MEC’s and MPMC are encountered. Divisional staff need only record these when they are encountered outside of a construction environment – See OC 18/12. They should be recorded on an IRF Ordinary (IRF O) against the relevant dutyholder and site.

Asbestos license assessments

Specific guidance on recording asbestos license assessments is contained within SIM 02/2008/03. Visits to notified work should be recorded using the IRF C.

Chargeable work

Specific guidance on recording chargeable work is contained within:

• OM 2008/12 – Cost recovery for conventional health and safety at major hazard sites HID/ ND
• OM 2009/01 – The regulation of conventional health and safety on UK nuclear sites

Recording Advice / Education/ Promotional 'SHAD' Work (A/E/P)

A significant element of the Division’s 09-10 Plan involves A/E/P operational work. Unless duty holder specific or indicated otherwise below ALL such work should be recorded as a SHAD against the following generic customer records:

• Ops Unit 1: Company FODCDOPS1SHADS (4036581).
• Ops Unit 2: Company FODCDOPS2SHADS (4045487).
• Ops Unit 3: Company FODCDOPS3SHADS (4030116).
• Ops Unit 4: Company FODCDOPS4SHADS (4119418).

A single Case should be raised for each intervention against the appropriate Ops Unit record. The Case should have the category ‘Partnership/ Stakeholder’, type ‘Advice/ Education/ Promotion’ and detail ‘N/A’. Where it is also important to record that this work has been undertaken in association with an important stakeholder, an additional A/E/P case should be created against that stakeholder and the two linked – see also below.

Time should be recorded in the normal way against the Advice/ Education/ Promotion activity with the most appropriate CD work stream category selected.

CPA (Construction Plant-hire Association)

HSAO’s / CO’s working with mobile crane hire companies on the promotion of CPA model conditions should record this work as notes against Case 4155743.

Time should be recorded in the normal way against the Advice/ Education/ Promotion activity with the ‘CD Crane Suppliers & Hirers’ work stream category selected.

Builders merchants and tool hire shops

Specific A/E/P work on silica is required during the 09-10 period. This should be recorded as a note against Case 4154427.

Time should be recorded in the normal way against the advice/education/promotion activity with the ‘CD Tool hirers & builders merchants’ work stream category selected.

Working Well Together (WWT)

All WWT work should be recorded against the following cases that have been established to capture specific types of WWT work.

WWT Ops 1 (site 416357162)

• WWT Op’s 1 SHAD’s – case 4156955
• WWT Op’s 1 DAD’s – case 4156952
• WWT Op’s 1 White van roadshows – case 4156967
• WWT Op’s 1 Mock trials – case 4156963

WWT Ops 2 (site 4163567)

• WWT Op’s 2 SHAD’s – case 4156969
• WWT Op’s 2 DAD’s – case 4156967
• WWT Op’s 2 White van roadshows – case 4156970
• WWT Op’s 2 Mock trials – case 4156971

WWT Ops 3 (site 4163568)

• WWT Op’s 3 SHAD’s – case 4156972
• WWT Op’s 3 DAD’s – case 4156973
• WWT Op’s 3 White van roadshows – case 4156975
• WWT Op’s 3 Mock trials – case 4156976

WWT Ops 4 (site 4163571)

• WWT Op’s 4 SHAD’s – case 4156977
• WWT Op’s 4 DAD’s – case 4156978
• WWT Op’s 4 White van roadshows – case 4156979
• WWT Op’s 4 Mock trials – case 4156981

All of these cases have been created against the generic Working Well Together customer (customer 4163561) and are linked to master case 4156962. Where other types of WWT work are undertaken, a new work type case should be created and related to this master case. The case should have the category ‘partnership/stakeholder’, type ‘advice/education/promotion’ and detail ‘N/A’.

Time should be recorded in the normal way against the advice/education/promotion activity with the ‘CD SME Engagement/ WWT’ work stream category selected.

Recording Local Authority Partnership Working (LACE)

Various elements of work during 09/10 involve increasing the extent and effectiveness of Local Authority health and safety intervention in the construction industry.

When recording this work a case should be raised against the relevant LA dutyholder. The case should have the category ‘Partnership/ stakeholder’, type ‘EA Partnership’ and detail ‘N/A’.  This case should also be linked to the master case set up to monitor progress with this work: Case 4151604. Time should be recorded in the normal way against the Stakeholder Engagement activity with the ‘CD LACE’ category selected.

Recording OHI investigations of non-mandatory manual handling accidents

A detailed protocol exists for reporting on this work (EDRM file ref: 2009/57775). Selected investigations should be recorded on COIN as an investigation case in line with existing procedures. This case should also be linked to the master case set up to monitor progress with this work: Case 4104651.

Time should be recorded in the normal way with the ‘CD MSD Project’ category selected.

Complaints

In line with existing instructions, all time spent investigating a complaint by an Inspector should be recorded as an investigation.

All complaint work undertaken by Band 5 Compliance officers should be recorded as a complaint FU.

Investigation and enforcement

All investigation and enforcement work should be recorded in line with the work recording OM and existing COIN procedures. It is important to note that

• All contact time for investigation and enforcement activities should be linked to a case and category. As ‘CD Construction Other’ can now be used for time recording purposes there should be no occasion where a work steam category cannot be used.
• All non-contact time for investigation and enforcement activities should also be linked to a specific case. The ‘work context’ field should be set to the value ‘OFF’ (office non-contact). Categories are not required to be allocated for this work.

All FOD work recording category selection

In the majority of instances divisional staff will be able to record their work using the CD specific categories detailed above. However, other ‘All FOD’ categories are also available which should be used as appropriate:

• Asbestos management – For use when dealing with asbestos duty to manage.
• LASP – For use whenever working in partnership with LA’s as a co-regulator, including interpreting and applying the Enforcing Authority Regulations.
• Product – All work on the initial integrity of equipment or other supply of equipment and substances.
• REACH – For all work relating to the registration, evaluation, authorisation and Restriction of Chemicals Regulations.
• Vulnerable workers – Including migrant workers, and those employed as ‘contract labour’.

Training and mentoring of B4 inspectors by Band2/3 staff

Previously there has been no requirement to allocate a category to time spent against the training or mentoring of B4 inspectors. However, the construction B4 fixed term inspectors project includes a requirement to evaluate the cost/ impact of this recruitment process on B2/3 operational efficiency.

Any non contact time spent on training/ mentoring a B4 within the 09-10 work year should therefore be recorded against the following category:

• Mentor/manage Band 4T – for Band 4 trainees.
• Mentor/manage Band 4FTA – for construction Band 4 fixed term inspectors

Note that in line with UWR activity descriptions:

• All time spent managing Band 4 staff by B2’s should be recorded against ‘Management’.
• All time spend mentoring Band 4 staff by B3’s should be recorded against ‘Advice, education and promotion'.

Appendix 1 – Work recording aide memoir

Category	Definition	Visit Recording Information (Proactive work only. Investigations and enforcement should be recorded using Cases)
CD Refurb/ Repair/ Maint/	All work associated with refurbishment, repair or maintenance to ANY existing building including: Refurbishment work linked to specific NLI clients Structural and re-roofing work Extensive internal / external renovation Soft strip Minor, domestic single storey etc extension Maintenance/ repair work – e.g. gutter replacement, roof repairs, mortar pointing, work by tradesmen Demolition/ site preparation where part of an overall refurbishment project	IRF C Relate the refurbishment work associated with specified clients to any relevant client master cases
CD Homebuild	All work associated with NEW residential buildings including: Houses, flats, apartments, high-rise buildings Homebuilders and Developers Houses, flats, apartments Homebuild specific major projects or NLI/ LLI interventions Demolition/ site preparation where part of an overall homebuild project	IRF C
CD Major Projects & Interventions	Work linked to major projects or NLI/LLI interventions. National lead inspector project plans Only record where there is an agreed written intervention plan in place for the project, or where the work is associated with a planned NLI/LLI initiative EXCEPT where Refurb/ Repair/ Maint or Homebuild specific	IRF C - Visits for Major Projects/ NLI/ LLI should be recorded on the appropriate master case for the project/intervention.
CD Asbestos Licensing	All assessment, waiver and notification inspection work associated with asbestos licence duty holders.	Asbestos Licence Service Order - Use for Licence Assessment Visits. Set up by ALU IRF C - Inspections of notifiable work and waiver requests where information is of particular note
CD Crane Suppliers & Hirers	All work by nominated inspectors on tower crane suppliers HSAO work with CPA on the training of hire desk staff on contract lifts	IRF C - Visits by nominated inspectors Record as notes against case 4155743
CD Construction Other	All work not otherwise captured by another work stream including: Disc of CDM duties where not captured elsewhere. Construction of NEW non-residential buildings such as factories, hospitals, schools, shops, leisure facilities, offices, care homes Civil engineering and Utility work Demolition and site preparation where not included above	IRF C
CD Tool Hirers & Builders Merchants	All silica awareness promotional work including via tool hirers and builders merchants	Record as notes against case 4154427
CD LACE	All work to increase the extent/ effectiveness of LA enforcers on H&S issues within construction	Partnership/Stakeholder Case, Type: EA Partnership against relevant LA duty holder and link to master case 4151604
CD MSD Project	All work linked to the inv of construction non-mandatory MH accidents by OHI’s	Investigation Case - Record against relevant duty holder and link to master case 4104651
CD SME Engagement/ WWT	All work to advise and educate SME’s, including WWT	SHAD Case – for WWT record against most relevant case linked to master case 4156962
CD Initiative	Use ONLY when specified with an inspection initiative.	IRF C
Generic SHAD customer records by Ops regions. Cases are Partnership Ops Unit1: FODCDOPS1SHADS (4036581) Ops Unit3: FODCDOPS3SHADS (4030116) Ops Unit2: FODCDOPS2SHADS (4045487) Ops Unit4: FODCDOPS4SHADS (4119418)

Appendix 2 - IRF work stream rating

Risk Control Indicators – Assessment Scale: each work stream should be assessed against the following 1-6 scale.
1	2	3	4	5	6
High standards with some aspects meeting best practice.	Good standards meeting minimum legal requirements	One or more minor shortcomings are present. As these shortcomings are not serious, they can be dealt with informally with oral advice.	Standards are patchy. It is necessary to address one or more shortcomings by giving formal instructions for remedial action to be taken. Formal instructions may be implemented by, eg, obtaining a verbal undertaking from the company to take specific action, sending a letter, or physical removal/ disposal of items.	Standards generally unsatisfactory. Typically, at least one contravention that gives rise to a discernible risk gap.	Standards unacceptable. Unless application of the EMM identifies duty holder factors that provide strong mitigation, the issuing of a notice and/or prosecution is likely to be appropriate.

Workplan Themes and Topics	CD Work Streams Cross Cutting
* Approach client and CDM-C when notice served on welfare, contractors arrangements & asbestos	Refurbishment / Maintenance / Repair	Homebuild	Major Projects & Interventions	Asbestos Licensing	Construction Other	Crane Suppliers & Hirers
Well Managed Projects
CDM2007 * (inc competence & client leadership)
Occupational Health Management
Worker Engagement
Leadership
Small Sites Strategy

Workplan Themes and Topics	CD Work Streams Common Topics
* Approach client and CDM-C when notice served on welfare, contractors arrangements & asbestos	Refurbishment / Maintenance / Repair	Homebuild	Major Projects & Interventions	Asbestos Licensing	Construction Other	Crane Suppliers & Hirers
Asbestos* (inc information, management and working with)
Falls, Transport, Good Order and Welfare*

Workplan Themes and Topics	CD Work Streams Common Topics
* Approach client and CDM-C when notice served on welfare, contractors arrangements & asbestos	Refurbishment / Maintenance / Repair	Homebuild	Major Projects & Interventions	Asbestos Licensing	Construction Other	Crane Suppliers & Hirers
Quick Hitches					D E P E N D S O N S I T E
Lifting Operations (inc tower, mobile & self erecting cranes)
Manual Handling
Fire
Domestic/ Minor Commercial Roof Repair
Silica
Structural Stability/Temp Works
Timberframe

Appendix 3 - IRF inspection ratings scores for company wide performance

Competence and attitude of management
Rating	Descriptor
1	Best Practise: Management know the relevant health and safety standards, have put them into effect and check they are applied correctly. There is clear evidence of effective self-regulation with standards being monitored and refined. Directors/senior managers are visibly demonstrating effective leadership. Good evidence of worker involvement in organisational issues and in day to day activities. Full compliance with the approach listed in HS(G)65.
2	Strong Evidence that management are up to the task: Management generally enthusiastic and competent with either: (i) effective systems in place for other business processes (e.g. quality assurance) but with knowledge gaps for health and safety requirements, or (ii) good health and safety knowledge with systems requiring improvement. Directors/senior managers demonstrate leadership. Worker involvement is identified but no consistent evidence of a formal system in place. There is potential for good performance and reasonable compliance with the HS(G)65 approach.
3	Some evidence that management are up to the task: Management are knowledgeable about relevant health and safety standards but there has been little effort to adopt a proactive approach to health and safety management. However, senior managers volunteer their thoughts as the inspection progresses and appear to be committed to adopting a more proactive approach. At least one Director/senior manager is willing to take a visible leadership role. Management are willing to commit to a cooperative approach with workers to health and safety management. There is general confidence that the recommendations resulting from the inspection will be put into place.
4	Management are ambivalent about health and safety: Management have only a patchy knowledge of relevant standards and there is little or no evidence that a proactive approach to ongoing health and safety management has been adopted. However, senior managers recognise the need to satisfy explicit statutory requirements and there is some prospect that a more proactive approach may be adopted. Limited involvement of workers in health and safety management.
5	Management are not up to the task: Management have significant shortcomings in their knowledge of relevant standards. Management do not appear to be willing to instigate a proactive approach and have not recognised that health and safety is an issue where they need to be personally involved. Individual Directors/senior managers are content to neglect their responsibilities. No evidence of worker involvement. There is uncertainty as to how they will respond to the findings from the inspection.
6	Management avoid the task and/or connive in cutting corners: There is a negative approach to accepting legal duties and management dispute the relevance or validity of recognised benchmark standards. Totally ineffective in the management of health and safety. Individual directors/senior managers are knowingly consenting to or conniving in the company’s failings. The employer is hostile to worker involvement. The findings from the inspection are likely to be ignored.

Health and Safety assessment scale
Rating	State of compliance	Descriptor
1	High Standards	High standards. Some aspects meet best practice.
2	Good Standards	Good standards. Meet minimum legal requirements.
3	Minor shortcomings	One or more minor shortcomings are present. As these shortcomings are not serious, they can be dealt with informally with oral advice.
4	Standards Patchy	Standards are patchy. It is necessary to address one or more shortcomings by giving formal instructions for remedial action to be taken. Formal instructions may be implemented by, eg, obtaining a verbal undertaking from the company to take specific action, sending a letter, or physical removal/ disposal of items.
5	Standards Unsatisfactory	Standards generally unsatisfactory. Typically, at least one contravention that gives rise to a discernible risk gap.
6	Standards Unacceptable	Standards unacceptable. Unless application of the EMM identifies duty holder factors that provide strong mitigation, the issuing of a notice and/or prosecution is likely to be appropriate.

Health and Safety assessment scale
Rating	State of compliance	Descriptor
1	Compliance	Good, clean provision. Would be content to use it yourself.
2	Minor non-compliance	Welfare facilities need cleaning, temporary absence of consumables such as soap or towels.
3	Inadequate provision	No heated water, or very dirty welfare facilities, or too few toilets.
4	Major non-compliance	No toilet or washing facilities, or welfare facilities so poor as to be unfit for use.